A local trustee is not immunity¶

Stéfane Fermigier

Download the PDF

Abstract¶

In a trustee-model cloud offer a local operator runs a US vendor's software in a local data centre. That settles residency and raises the bar on silent access where keys are held locally. It does not put the systems out of reach of US law, which follows control of the software wherever the servers sit: the CLOUD Act hooks on control, Section 702 of FISA compels providers programmatically, and Executive Order 12333 needs no request at all. The software, the update channel and the vendor's support access stay where they were, and on the vendor's proprietary interfaces the cost of leaving is unchanged, so the price a buyer can be charged is unchanged whether or not any authority ever asks for anything.

What a trustee model changes, and what stays with the US vendor whose software it runs.

About this paper¶

Cite this paper¶

Fermigier, S. (2026). A local trustee is not immunity.
Policy paper, Abilian Econ Lab.
https://econ.lab.abilian.com/papers/local-trustee-models/